The defendant is charged [in count __]
with bribe receiving by a juror. The statute defining this offense reads in
pertinent part as follows:

a juror is guilty of bribe
receiving by a juror if (he/she) (solicits / accepts / agrees to accept) from
another person any benefit as consideration for (his/her) decision or vote.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Benefit soughtThe first element is that the
defendant (solicited / accepted / agreed to accept) a benefit from <insert
name of third party>. "Benefit"
means monetary advantage, or anything regarded by the beneficiary as a monetary
advantage, including any benefit to any person or entity in whose welfare the
beneficiary is interested. The mere act of soliciting a benefit is sufficient.
In this case the state alleges that the benefit involves <insert alleged
benefit>.

Element 2 - By jurorThe second element is that the
defendant was a juror on the date of the offense. A "juror"
is any person who has been drawn or summoned to serve or act as a juror in any
court.

Element
3 - As
consideration for voteThe third element is that the benefit
was consideration for the juror's vote or decision. The defendant and <insert
name of third party> must have both understood that the juror's decision or
vote would be influenced by (his/her) acceptance of the <insert alleged
benefit>.

Conclusion

In summary, the state must prove
beyond a reasonable doubt that 1) the defendant (solicited / accepted / agreed
to accept) a benefit from <insert name of third party>, 2) the defendant
was a juror, and 3) the defendant and <insert name of third party> both
intended that the benefit would influence the juror's decision or vote.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of bribe
receiving by a juror, then you shall find the defendant guilty. On the other
hand, if you unanimously find that the state has failed to prove beyond a
reasonable doubt any of the elements, you shall then find the defendant not
guilty.